Call to Action: Respond to FHFA's Request for Input on Limited English Proficiency Borrowers

July 25, 2017 8:32 AM |
Anonymous

Dear MAA Member:

On May 25th the Federal Housing Finance Agency (FHFA) issued a “request for input” (RFI) to get public views “on issues faced by qualified limited English proficiency (LEP) borrowers to learn more about the procedures and tools that loan originators, servicers, and other parties in the mortgage lending process presently employ to assist LEP borrowers, to identify existing requirements, including laws and regulations that guide practices for interacting with LEP borrowers, and to better understand the challenges in effectively servicing this population.”

MBA strongly supports efforts to expand homeownership opportunities and looks forward to working with FHFA and others towards that goal. MBA will respond to this RFI to encourage FHFA to provide guidance on how GSE originators and servicers can better serve the LEP population and share best practices from our members who lead in this area.

One idea that MBA cannot support is the possibility that FHFA would put a question regarding a borrower’s “preferred language” on the Uniform Residential Loan Application (URLA) that all GSE borrowers or their lender must complete. A year ago, MBA and other industry groups were able to convince FHFA to focus on developing resources and guidance to assist LEP borrowers before putting this question on the form. However, it appears that FHFA is contemplating doing so again, despite many issues and potential risks that remain unaddressed.

We believe that inclusion of such a question would be premature and potentially harmful to a lender or servicer’s relationship with their customer The borrower might have expectations about service in another language that a lender or servicer cannot provide, or a borrower might erroneously believe the lender intended to discriminate against them or otherwise treat them differently. Neither outcome is consistent with the type of customer service we know MBA members strive to provide.

While MBA will be submitting our own response to this RFI, you can help NOW by submitting your own letter and making our collective voice louder. Take action today and let FHFA know that the time is not right to put a question about language preference on the URLA.

MBA's policy experts have produced sample language that you can use when responding to this RFI.Simplyclick“Take Action,”select "Language Access" as the topic, fill in the required information, andcopy/paste the sample language into the"Comments" box. If possible, personalize your response with your own individual experience and insight to make your letter even more effective.

If you encounter any issues, please contact Peter Shapiro at 202-557-2933 or pshapiro@mba.org. If you did not receive this Call to Action from maa@mba.org you may not have an active MAA membership. Please click here to sign up for MAA.

By responding to a Call to Action alert from MAA, opening an email from MAA, registering for an MBA conference or contributing to MBA’s political action committee (MORPAC), you are agreeing to renew your membership in MAA for one year (365 days) from the date of your action. Please note that you may terminate your membership at any time by emailing maa@mba.org. There are no membership dues.

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